Whistleblower law in Italy #
Italy transposed EU Directive 2019/1937 through Decreto Legislativo 10 marzo 2023, n. 24. Companies with 50 or more employees (and all companies with a Model 231 compliance program regardless of size) must operate an internal whistleblower reporting channel. ANAC issued its first retaliation fine in July 2024.
Law #
Decreto Legislativo 10 marzo 2023, n. 24.
Who must comply #
Companies with 50+ employees (and all companies with a Model 231 compliance program regardless of size). Deadline was July 15, 2023 (250+ employees) and December 17, 2023 (50–249 employees). Source: Norton Rose Fulbright
Penalties #
- Not establishing reporting channels or non-compliant procedures: €10,000–€50,000. Source: Norton Rose Fulbright
- Retaliation or obstruction: €10,000–€50,000. Source: Hogan Lovells
- Breaching confidentiality of reporter identity: €10,000–€50,000. Source: Norton Rose Fulbright
- False reporting by whistleblower: €500–€2,500. Source: Norton Rose Fulbright
Enforcement #
ANAC (Autorità Nazionale Anticorruzione). ANAC issued its first retaliation fine in July 2024. Source: Cleary Gottlieb